On Thursday Mr Trump – who famously dubbed Joe Biden “sleepy Joe” – repeatedly sat slumped back in his chair with his eyes firmly shut, occasionally moving his headnomin or shifting in his seat.
It has been a common stance adopted by the Republican nominee throughout the New York hearing.
Mr Trump has appeared notably more engaged – muttering to his lawyers or turning to face the witness – when his lawyers have been cross-examining, or when footage or audio is being played.
On April 15, the first day of jury selection, the New York Times claimed that Mr Trump fell asleep during the first few hours of the trial.
He was reportedly seen closing his eyes with his head drooping down and his mouth hanging open before he jolted awake.
Mr Trump, who is required to attend the criminal trial, frequently taunts his political rival, Mr Biden, accusing him of snoozing.
On Wednesday he wrote on Truth Social: “Where’s sleepy Joe? He’s sleeping, that’s where!”
Democrats have used Mr Trump’s apparent drowsiness to attack the former president.
“If Trump is too old and weak to stay awake at his own criminal trial, what do you think will happen in the Situation Room?” Dan Pfeiffer, former senior adviser to Barack Obama, previously said.
“Trump is defeated, he’s obviously sleeping, he’s tired, and low energy … he’s sleepy Donald Trump”, Democrat congressman Robert Garcia said.
He added: “While at the same time we have Biden, actually leading the country, doing the right thing.”
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